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EN Revision Imported Date : 8/18/2020 EMERGENCY PROCEDURE ERROR POTENTIALLY PREVENTING TIMELY COMPLETION OF EMERGENCY CORE COOLING SYSTEM RECIRCULATION ALIGNMENT At 0815 CDT on 7/30/2020, it was determined that a procedural error in emergency procedure ES1.3, Transfer to Cold Leg Recirculation, could delay realignment from emergency core cooling system (ECCS) injection phase to recirculation phase under lower plant operational modes. It is noted this scenario is postulated to occur only when the boron dilution mitigation system is operable in lower modes of operation as per Technical Specification 3.3.9 (required operable in Mode 2 (below P-6), 3, 4 and 5). Current plant conditions require this feature nonfunctional so this issue does not impact current plant conditions. This condition is not bounded by existing design and licensing documents; however, it poses no current impact to the health and safety of the public or plant personnel. Therefore, this event is being reported as an eight-hour, non-emergency notification per 10 CFR 50.72(b)(3)(ii)(B). The NRC Resident Inspector has been notified.

• * * RETRACTION ON 8/17/2020 AT 1603 EDT FROM JOSH COPELAND TO KERBY SCALES * * *

Event Notification (EN) 54806, made on 7/30/2020, is being retracted because re-evaluation performed subsequent to the notification has demonstrated that the error in Emergency Operating Procedure ES1.3 would not have resulted in a condition outside of the current licensing basis analyses of record for the Callaway Plant. This re-evaluation addressed core effects, containment pressure-temperature and radiological consequences analyses, documented in the plant's corrective action program. The re-evaluation has led to the conclusion that the procedural error in ES1.3 would not have prevented any system required to be OPERABLE by the Technical Specifications from performing its specified safety functions. With all systems capable of performing their specified safety functions, the current licensing basis analyses of record for Callaway Plant remain valid and bounding. Based on these considerations, it has been determined that the condition reported in EN 54806 did not result in the plant being in an unanalyzed condition that significantly degraded plant safety. Consequently the condition did not meet the criteria for an 8-hour notification per 10 CFR 50.72(b)(3)(ii)(B) for an unanalyzed condition that significantly degrades safety. The NRC Resident Inspector has been notified of this Event Notification retraction. Notified R4DO (Taylor)